The Council of Europe’s Committee of Ministers has called on Georgia to revise its freedom of assembly laws and build a “fully enabling environment” for NGOs that monitor protests and provide legal aid. The appeal, adopted at the Committee’s June 9-11 meeting, sits inside the execution of the European Court of Human Rights judgment in Makarashvili and Others v. Georgia and asks Tbilisi to bring its protest legislation and practice into line with the European Convention on Human Rights.
The decision names a constituency whose work it wants protected: civil society organizations that watch demonstrations and give legal help to participants. That constituency is itself shrinking. In March 2026, the Georgian Young Lawyers’ Association, the country’s leading legal aid provider, said it would scale back services in what it called a “crisis mode,” three months before the Committee of Ministers asked the state to make space for that work.
The Strasbourg decision, in the Committee’s own words
The Committee of Ministers’ deputies opened the decision by reiterating that “the right to freedom of assembly is a fundamental right in a democratic society and, like the right to freedom of expression, is one of the foundations of such a society.” They noted the payment of “just satisfaction” in the Makarashvili case but added that “the individual measures required include ensuring the applicants’ continuing freedom to take part in peaceful demonstrations, which depends on progress in the general measures.”
The deputies recorded “deep concern” over “legislative and enforcement measures which produce a chilling effect on the exercise of the right of freedom of assembly” and called on Georgian authorities “to thoroughly revise the relevant legislation and practices and align them with the Convention standards, with a view to preventing disproportionate and arbitrary administrative arrest/detention and conviction, including criminal conviction, excessive sanctions, and ensuring the overall fairness of proceedings.” They also encouraged Tbilisi “to engage in meaningful consultations with relevant stakeholders and Council of Europe expert bodies” during any reform process.
Why the Makarashvili case is the trigger
The decision sits inside the Council of Europe’s supervision of the Makarashvili and Others v. Georgia judgment, in which the European Court of Human Rights found violations of the applicants’ rights to freedom of assembly and, in one applicant’s case, the right to a fair trial. The Makarashvili judgment under Council of Europe supervision is one of the longest-running execution files in the Committee’s queue.
The Committee noted that compensation awarded in the case has been paid. What it has not been able to confirm is that the original applicants can take part in peaceful demonstrations without risk. The deputies tied the applicants’ protection to the reform track covering every protester in Georgia, which is what makes the decision a general appeal rather than a single-case follow-up.
The Committee also called on Georgian authorities “to provide updated information on judicial and law enforcement practices related to administrative arrests/detentions and convictions in the context of demonstrations, along with statistical data.” That reporting requirement, if honored, would give Strasbourg an empirical handle on the gap between what Tbilisi says and what is happening on Rustaveli Avenue and in courtrooms around the country.
The party the decision actually names
The most concrete demand in the decision is not aimed at the courts or the police. It is aimed at civil society. The deputies called on Georgian authorities to ensure a “fully enabling environment” for NGOs that monitor assemblies and provide legal aid, and to engage in consultations with relevant stakeholders and Council of Europe expert bodies.
Recalling the important role of civil society in monitoring compliance with the Convention and the Court’s judgments, the deputies also called on the authorities to ensure fully enabling environment for the effective operation of NGOs which monitor assemblies and provide legal assistance to their participants.
That is the language of the Committee of Ministers’ deputies, adopted at the Committee’s June 9-11 meeting in Strasbourg as part of the Makarashvili execution file. It is also the constituency the Georgian government has been legislating against for over a year. On March 4, 2026, parliament adopted a package restricting grants, political activity, lobbying, and government non-recognition, a series of changes civil society groups have described as a parallel crackdown on the organizations that document the crackdown itself.
The legal aid gap the decision lands on
The demand for a “fully enabling environment” for legal-aid NGOs runs into a problem: the environment is contracting. The Georgian Young Lawyers’ Association, GYLA, said on March 14, 2026 that it would cut its free legal aid services and focus only on strategic cases, entering what it called “crisis mode” amid growing repression. GYLA is the country’s most prominent provider of free legal defense to protesters, the kind of organization the European Court of Human Rights assumes will be there when applicants exhaust domestic remedies before reaching Strasbourg.
Three months after GYLA’s announcement, the Committee of Ministers asked Georgia to make space for that work. The decision does not name GYLA, but it names the category of work GYLA was pulling back from. GYLA has delivered more than 1.3 million free legal consultations and services across Georgia’s nine regions since its founding in 1994, and its pullback will leave “thousands of citizens” without the daily in-person, telephone, and online consultations, document preparation, and court representation they had relied on.
| What the Committee asked for | What is happening on the ground |
|---|---|
| “Fully enabling environment” for NGOs monitoring assemblies and giving legal help | GYLA said on March 14, 2026 it would cut free legal aid services and focus only on strategic cases, citing “crisis mode” amid growing repression |
| Legislation aligned with Convention standards on assembly | Four waves of new protest laws in 2025 tightened, not loosened, the legal framework for demonstrations |
| Updated statistics on arrests, detentions, and convictions linked to demonstrations | First criminal conviction for “repeated road blockage” recorded in May 2026, with a nine-month jail sentence; frozen bank accounts over unnotified fines reported in April 2026 |
| Consultations with Council of Europe expert bodies | No Georgian government response to the consultation call has been published |
The GYLA pullback is not an isolated signal. In April 2026, protesters and journalists reported that their bank accounts had been frozen over unnotified “road blockage” fines, with the freeze triggered without notice and without the alleged offenders first being informed. The mechanism depends on the existence of legal aid providers who can challenge the fines; their absence makes the fines stick.
The protest laws the deputies are effectively targeting
The Committee of Ministers’ decision does not list specific Georgian statutes, but its language on “disproportionate and arbitrary administrative arrest/detention and conviction, including criminal conviction, excessive sanctions” maps onto a legislative track that has run in the opposite direction over the past eighteen months. The pattern was documented in detail by Human Rights Watch in late 2025 and by an intergovernmental review of new Georgian protest laws.
- February 2025: maximum detention for protest-related administrative offenses extended from 15 days to 60 days.
- February 2025: a new offense of “verbal insult” of officials created, punishable by up to 45 days in custody.
- February 2025: spontaneous demonstrations now required to give advance notification, with indoor gatherings requiring written authorization.
- July 2025: parliament approved 30 to 60 days of detention for individuals with outstanding fines who commit even minor protest-related violations, tying unpaid fines to custodial sentences.
- October 2025: amendments reclassified repeated mask-wearing, road blockages, erecting temporary structures, or joining a police-blocked protest as felonies, punishable by up to two years in prison for participants and up to four years for organizers.
The first criminal conviction under that October 2025 escalation came on May 29, 2026, when protester Zurab Menteshashvili was sentenced to nine months in jail in what Civil Georgia called the first criminal conviction for “repeated road blockage.” The deputies’ reference to “criminal conviction” in the Strasbourg decision is a direct response to that shift in the law.
Tbilisi’s posture
The Georgian government has rejected the framing of its protest laws as repressive, characterizing international criticism as foreign interference and misinformation. Georgian President Mikheil Kavelashvili accused outlets including the BBC of spreading “completely unverified information” that harms Georgia’s reputation.
The Committee of Ministers’ response is procedural rather than rhetorical. By asking the authorities to “engage in meaningful consultations with relevant stakeholders and Council of Europe expert bodies,” the deputies left an opening for talks without conceding the underlying point that the laws as they stand are out of line with Convention standards. Documentation of how the crackdown on Georgian protesters unfolded over 500 days is part of the record the Council of Europe can lean on when it returns to the case.
Why a 77-case backlog changes the math
The Makarashvili execution is one file in a much larger queue. The Council of Europe’s Committee of Ministers said on March 26, 2026 that 77 European Court of Human Rights judgments against Georgia are pending execution, covering freedom of assembly, fair trial, and other Convention rights. The breadth of the backlog is what turns a single June decision into an ongoing supervisory relationship with measurable reporting deadlines.
The June decision requires Tbilisi to report back with updated statistics on administrative arrests, detentions, and convictions linked to demonstrations, the kind of dataset that did not exist when the Makarashvili case was first heard. The Committee of Ministers will keep monitoring the file.
The broader pattern, taken alongside parallel EU pressure over visa liberalization, suggests the Makarashvili decision is unlikely to be the last word on Georgia’s protest laws this year. The visa dialogue Tbilisi and Brussels opened on June 11 is a parallel track, and the Council of Europe supervision is another, with the same protest law as the test case both tracks will have to judge.
Frequently Asked Questions
What did the Council of Europe ask Georgia to do?
At its June 9-11 meeting, the Council of Europe’s Committee of Ministers called on Georgian authorities to revise their protest legislation and practice, bring them into line with the European Convention on Human Rights, and create a “fully enabling environment” for NGOs that monitor demonstrations and provide legal assistance to participants. The Committee also asked for updated statistics on arrests, detentions, and convictions linked to demonstrations.
Why is the Makarashvili and Others v. Georgia case the trigger?
The Committee of Ministers supervises the execution of European Court of Human Rights judgments. Makarashvili and Others v. Georgia is the file under active supervision: the Court found violations of the applicants’ rights to freedom of assembly and, in one case, the right to a fair trial. Compensation has been paid, but the Committee says the applicants’ continuing ability to demonstrate freely depends on broader reforms.
Which Georgian protest laws is the Committee of Ministers effectively targeting?
The decision does not name statutes, but its language covers the package of laws Georgia passed in 2025: extending administrative detention from 15 to 60 days in February; a “verbal insult” offense punishable by up to 45 days; advance-notice requirements for spontaneous demonstrations; 30 to 60 days of detention for unpaid-fine offenders in July; and felony reclassification in October with up to two years for participants and up to four years for organizers.
What role is the decision asking civil society to play?
The Committee of Ministers called on Georgia to ensure a “fully enabling environment” for NGOs that monitor assemblies and provide legal assistance, framing civil society as a partner in monitoring compliance with the European Convention on Human Rights. That framing puts organizations like the Georgian Young Lawyers’ Association at the center of the supervisory relationship, even as those organizations say they are pulling back from service delivery under domestic pressure.
Has the Georgian government agreed to revise the laws?
No public commitment to revise the protest laws has been issued in response to the June decision. The Committee’s call to “engage in meaningful consultations with relevant stakeholders and Council of Europe expert bodies” remains open. The Committee will continue to monitor Georgia’s execution of the Makarashvili judgment and the broader 77-case backlog.
